NUCLEAR 

TERRORISM 

RESPONSE PLANS

Major Cities Could 

Benefit from Federal 

Guidance on 

Responding to 

Nuclear and 

Radiological Attacks

Report to the Chairman, Committee on 

Homeland Security and Governmental 

Affairs, U.S. Senate

September 2013

GAO-13-736

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-736, a report to the 

Chairman, Committee on Homeland Security 

and Governmental Affairs, U.S. Senate

September 2013

NUCLEAR TERRORISM RESPONSE PLANS

Major Cities Could Benefit from Federal Guidance 

on Responding to Nuclear and Radiological Attacks

Why GAO Did This Study

A terrorist attack in a major city using 

an RDD or an IND could result not only 

in the loss of life but also have 

enormous psychological and economic 

impacts. Major cities are assumed to 

be preferred targets of such attacks, 

and local governments, along with their 

states, have primary responsibilities for 

early response (within the first 24 

hours), with assistance from federal 

sources, as necessary, coming later. A 

disjointed or untimely response could 

increase the impact and undermine 

public confidence in federal, state and 

local governments’ ability to respond to 

an attack. 

GAO was asked to review issues 

related to response preparedness for 

RDD and IND attacks. This report 

examines major cities’ (1) assessment

of RDD and IND risks and

development of response plans, (2) 

perceptions of their abilities to respond 

within the first 24 hours, and (3) 

perceptions of the need for federal 

support in early response to these 

attacks. GAO primarily relied on 

questionnaire responses from 

emergency managers of 27 of the 31

major cities that the Department of 

Homeland Security considers to be at 

high risk for terrorist attack, the review 

of pertinent federal guidance, and 

interviews with FEMA officials and 

others.

What GAO Recommends

GAO recommends that FEMA develop 

guidance to clarify the early response

capabilities needed by cities for RDD 

and IND attacks. FEMA did not concur 

with this recommendation. GAO 

believes that gaps in early response 

abilities warrant federal attention and 

has clarified its recommendation.

What GAO Found

Many emergency managers from the 27 major cities responding to GAO’s 

questionnaire, although not all, reported that their city had assessed the risks of a 

terrorist attack using a radiological dispersal device (RDD) or improvised nuclear 

device (IND) and had ranked the risk of these attacks as lower than the risk of 

other hazards they face. Also, 11 of the 27 reported that they had completed 

RDD response plans, and 8 of the 27 reported that they had completed IND 

response plans. Some emergency managers for cities without specific RDD and 

IND response plans reported that they would rely on their city’s all hazards 

emergency operations plan or hazard management plan if attacked. Most cities 

that had RDD and IND response plans reported conducting exercises to validate 

the plans based on federal guidance.

Major cities varied widely in perceptions of their abilities to respond within the first 

24 hours of RDD and IND attacks (early response). For example, all 27 cities 

were perceived by their emergency managers as being able to conduct at least a 

few of the early response activities after an RDD attack, such as treating 

casualties, with assistance from other jurisdictions but not federal assistance.

Ten of those cities were perceived as not being able to conduct any of the 

response activities for an IND attack without federal assistance. GAO analysis 

found that these perceptions were not necessarily related to a city having RDD 

and IND response plans but rather related to their understanding of nuclear and 

radiological incidents and the capabilities needed for response according to 

information obtained from Federal Emergency Management Agency (FEMA) 

officials. GAO found limited federal planning guidance related to the early 

response capabilities needed by cities for the large RDD attack depicted in the 

national planning scenarios. Federal guidance may not be needed, according to 

FEMA officials, because they expect cities to address a more likely but smaller 

RDD attack—as they would a hazardous materials spill—with limited federal 

assistance. More federal planning guidance applicable to cities has been 

developed for IND response, but this guidance does not detail the early response 

capabilities needed by cities in relation to other sources of assistance. Without 

greater awareness of and additional federal guidance on the capabilities needed 

by cities for early response to these attacks, cities may not have the information 

they need to adequately prepare for and respond to them. This could lead to 

complications that result in greater loss of life and economic impacts. 

Most emergency managers reported perceived needs for federal technical and 

resource assistance to support their cities’ early response to RDD (19 of 27 

cities) and IND (21 of 27 cities) attacks. However, GAO found that federal 

guidance on the type and timing of such assistance is not readily available or 

understood by all emergency managers. This condition could lead to a disjointed 

and untimely response that might increase the consequences of either kind of 

attack. Emergency managers also reported a need for improved procedures and

more information that FEMA is addressing. In addition, most emergency 

managers reported their city needed federal funding to maintain current 

capabilities to respond to RDD and IND attacks. According to DHS guidance, 

response capabilities are developed through planning, training, equipping, and 

exercising, which are essential elements of an integrated, capability-based 

approach to preparedness. 

View GAO-13-736. For more information, 

contact David C. Trimble at (202) 512-3841 or 

trimbled@gao.gov.
Page i GAO-13-736 Nuclear Terrorism Response Plans

Letter 1

Background 6

Many Major Cities Assessed the Risk of RDD and IND Attacks as 

Lower Than Other Hazards They Face, and Few Had Developed 

Specific Response Plans 13

Major Cities Vary Widely in Perceptions of Their Abilities to 

Respond within 24 Hours of RDD and IND Attacks 16

Most Major Cities Expressed Need for Federal Support for Early 

Response to RDD and IND Attacks 25

Conclusions 33

Recommendation for Executive Action 34

Agency Comments and Our Evaluation 34

Appendix I Objectives, Scope, and Methodology 37

Appendix II Questionnaire 41

Appendix III Fiscal Year 2013 DHS Preparedness Grant Programs Funding 

Awarded 58

Appendix IV Comments from the Department of Homeland Security 59

Appendix V GAO Contact and Staff Acknowledgments 62

Tables

Table 1: Activities Associated with Each Core Capability for the 

Response Mission Area 9

Table 2: Radiological Dispersal Device (RDD) or Improvised 

Nuclear Device (IND) Attack Risk Assessment Approach 

for 27 Major Cities and the Percentage Ranking These 

Hazards as Lower Than Other Hazards They Face 14

Contents
Page ii GAO-13-736 Nuclear Terrorism Response Plans

Table 3: Number and Percentage of 27 Major Cities with Specific 

Radiological Dispersal Device (RDD) or Improvised 

Nuclear Device (IND) Response Plans 15

Table 4: Comparison of Characteristics of Radiological Dispersal 

Device (RDD) and Improvised Nuclear Device (IND) 

Attacks 24

Figures

Figure 1: Major Cities at High Risk for Terrorist Attack by FEMA 

Region 8

Figure 2: Conceptual Response Planning Framework for 

Radiological Dispersal Device (RDD) and Improvised 

Nuclear Device (IND) Attacks within the National 

Preparedness System 12

Figure 3: Amount of Perceived Early Response Ability of 27 Major 

Cities for Radiological Dispersal Device (RDD) and 

Improvised Nuclear Device (IND) Attacks 18

Figure 4: Anticipated Capability Requirements by Response Time 22

Figure 5: Anticipated Federal Technical and Resource Support for 

Core Capabilities Necessary for a Major City Early 

Response to an Improvised Nuclear Device (IND) Attack 28

Figure 6: Federal Radiological Dispersal Device (RDD) or 

Improvised Nuclear Device (IND) Response Topic Areas 

Identified by Major City Emergency Managers as Needed 

to Improve Early Response Capabilities 30
Page iii GAO-13-736 Nuclear Terrorism Response Plans

Abbreviations

DOD Department of Defense

DOE Department of Energy

DHS Department of Homeland Security

FEMA Federal Emergency Management Agency

FIOP Federal Interagency Operational Plan

HHS Department of Health and Human Services

IND improvised nuclear device

NNSA National Nuclear Security Administration

RDD radiological dispersal device

UASI Urban Areas Security Initiative

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Page 1 GAO-13-736 Nuclear Terrorism Response Plans

441 G St. N.W.

Washington, DC 20548

September 30, 2013

The Honorable Thomas R. Carper

Chairman

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Mr. Chairman:

A terrorist attack in a major city using a weapon of mass destruction 

would result in not only the loss of life but also enormous psychological 

and economic impacts. Since the terrorist attacks of September 11, 2001, 

concerns have intensified over major cities’ preparedness to respond to 

an attack using a radiological dispersal device (RDD)—a mechanism to 

deliberately release radioactive material in sufficient quantities to require 

protective actions—or an improvised nuclear device (IND)1

—a weapon 

fabricated using fissile material that produces a nuclear explosion.2 Urban 

centers of major cities are assumed to be preferred targets for a terrorist 

attack, and local governments, along with their states, would have 

primary responsibilities for early response—within the first 24 hours—until 

additional resources, if needed, arrive from the federal government.3 To 

prepare to respond early to an RDD or IND attack, cities will need to 

understand the risks and plan to respond if an attack occurs. According to 

a 2012 National Science and Technology Council report,4 the ability to 

prepare for such an attack and act decisively and appropriately in the first 

minutes and hours after an attack will require reliable information, 

capabilities, and tools to assist in planning and to effectively mitigate 

consequences. A disjointed or untimely response could put many 

 1

RDDs and INDs are considered weapons of mass destruction, along with chemical and 

biological weapons. See 18 U.S.C. § 2332a(c); 6 U.S.C. § 485(a)(6).

2

Fissile material is composed of atoms that can be split by neutrons in a self-sustaining 

chain reaction to release enormous amounts of energy. In nuclear weapons, the fission 

energy is released all at once to produce a violent explosion. The primary fissile materials 

are plutonium and uranium. 

3

The term “response,” refers to those capabilities necessary to save lives, protect property 

and the environment, and meet basic human needs after an incident has occurred. 

4

National Science and Technology Council, Nuclear Defense Research and Development 

Roadmap, Fiscal Years 2013-2017 (Washington, D.C.: Executive Office of the President, 

April 2012).
Page 2 GAO-13-736 Nuclear Terrorism Response Plans

additional lives at risk, increase economic consequences, and undermine 

the public’s confidence in the federal, state, and local governments’ ability 

to respond to such a crisis.

In March 2011, the President directed the Secretary of Homeland 

Security, Department of Homeland Security (DHS), to develop a national 

preparedness goal and design a national preparedness system to 

address the threats posing the greatest risk to the security of the nation, 

and to issue an annual national preparedness report.5 The national 

preparedness goal defines the core capabilities necessary to prepare for 

specific types of incidents, including acts of terrorism, cyber attacks, 

pandemics, and catastrophic natural disasters.6 In September 2011, DHS 

published the National Preparedness Goal,7 which stated that all levels of 

government and the whole community should present and assess risks in 

a similar manner to provide a common understanding of the threats and 

hazards confronting the country. Consistent with the National 

Preparedness Goal, the information gathered during a risk assessment 

will also enable a prioritization of preparedness efforts and provide an 

opportunity to identify capability requirements across all levels of 

government and the private sector. In this context, an RDD or IND attack 

would pose both a threat prior to the incident and a hazard after 

detonation.

As directed by the President, the national preparedness system is 

intended to guide activities to achieve the national preparedness goal.

Specifically, it is to provide guidance on the planning, organization, 

equipment, training, and exercises needed to develop and maintain 

domestic capabilities. The national preparedness system is to include a 

series of integrated national planning frameworks for five mission areas—

prevention, protection, mitigation, response, and recovery—built on basic 

plans that support an all hazards approach to preparedness. The all 

hazards approach allows emergency planners at all government levels to 

address common operational functions in their basic plans instead of 

 5

The White House, Presidential Policy Directive/PPD-8: National Preparedness 

(Washington, D.C.: Mar. 30, 2011). DHS, National Preparedness Report (Washington, 

D.C.: Mar. 30, 2012).

6

An incident is an occurrence or event—natural, technological, or human-caused—that 

requires a response to protect life, property, or the environment.

7

DHS, National Preparedness Goal, First Edition (Washington, D.C.: September 2011).
Page 3 GAO-13-736 Nuclear Terrorism Response Plans

having unique plans for every type of hazard. Each national planning 

framework is directed to include guidance to support corresponding 

planning at other governmental levels, including cities. The directive 

called for the national preparedness system to include development of a 

Federal Interagency Operational Plan (FIOP) to support each of the five 

mission area planning frameworks, such as the one for the response 

mission area.8 In November 2011, DHS published the National 

Preparedness System and has been working to implement this system.

9

The directive also recognizes that the national planning frameworks could 

include supplements, called annexes, describing additional planning 

guidance for particular hazard scenarios. DHS has previously prepared 

guidance in 2006 on planning assumptions for major attacks and natural 

disasters, including RDD and IND attacks, as a reference to help planners 

at all levels of government identify the potential scope, magnitude, and 

complexity of these events.

10 DHS stated in this guidance that this was 

done to establish a range of response capabilities to facilitate 

preparedness planning and exercising these plans. The 2008 National 

Response Framework, under revision, already includes a nuclear and 

radiological incident annex. According to Federal Emergency 

Management Agency (FEMA) officials, the FIOPs will likely include 

operational details for most, if not all of the national planning framework 

annexes.

The President also directed that the national preparedness system be 

consistent with the previously developed National Incident Management 

System, which provides a systematic and coordinated all hazards 

 8

The FIOP is intended to provide a detailed concept of operations, description of critical 

tasks and responsibilities, detailed resources, personnel, and sourcing requirements, and 

specific provisions for the delivery of capabilities by the federal government.

9

DHS, National Preparedness System (Washington, D.C.: November 2011).

10DHS, National Planning Scenarios (Washington, D.C.: March 2006). The planning 

scenarios include a large IND attack; biological attack-aerosol anthrax; biological disease 

outbreak-pandemic influenza; biological attack- plague; chemical attack-blister agent; 

chemical attack-toxic industrial chemicals; chemical attack- nerve agent; chemical attackchlorine tank explosion; natural disaster-major earthquake; natural disaster-major 

hurricane; radiological attack-RDD; explosive attack- bombing using improvised explosive 

device; biological attack-food contamination; biological attack-foreign animal disease (e.g., 

foot-and-mouth disease); and cyber attack.
Page 4 GAO-13-736 Nuclear Terrorism Response Plans

approach to incident management across all levels of government.11 The 

National Incident Management System sets forth a comprehensive 

national approach that recognizes that incidents typically begin and end 

locally and are managed on a daily basis at the lowest jurisdictional level. 

However, there are incidents in which successful management of 

operations will need the involvement of multiple jurisdictions, levels of 

government, functional agencies, and emergency responder disciplines. 

Effective response to an RDD or IND attack would require marshalling all 

available federal, state, and local resources to save lives and limit 

economic damage.

DHS has lead federal coordinating responsibility for attacks involving 

nuclear or radiological materials, including RDDs and INDs. FEMA, within 

DHS, has responsibility to reduce the loss of life and property, and protect 

the nation from all hazards, including terrorism. FEMA has a leadership 

role to coordinate the overall federal response to these attacks in close 

coordination with many other federal agencies and departments.12 Among 

other agencies, these include the Department of Energy (DOE), 

Department of Defense (DOD), and the Department of Health and Human 

Services (HHS). Within DOE, the semiautonomous National Nuclear 

Security Administration (NNSA) would lead the early federal interagency 

response to characterize the nature and dispersal of radioactive material 

in the event of an RDD or IND attack. DOD may provide support in 

response to requests for assistance from DHS, other federal agencies, as 

well as state and local governments.13 HHS would lead all federal public 

health and medical response to supplement state and local resources 

during a public health and medical disaster. In addition, the National 

Guard can provide governors with a wide array of response capabilities in 

detection/identification, search and rescue, patient decontamination, and 

medical care to relieve or augment first responders.

 11DHS, National Incident Management System (Washington, D.C.: December 2008). This 

document is an update from the original 2004 publication.

12FEMA accomplishes this responsibility through the Federal Radiological Preparedness 

Coordinating Committee. The federal response mechanisms include the Emergency 

Support Functions and supporting annexes to the National Response Framework, and 

existing emergency response plans that address nuclear and radiological incidents.

13Generally, DOD resources are committed only after approval by the Secretary of 

Defense or at the direction of the President.
Page 5 GAO-13-736 Nuclear Terrorism Response Plans

Since major cities are presumed to be preferred targets for terrorist 

attacks, you asked us to examine their concerns about RDD and IND 

attacks and how they perceive their ability to respond to them before 

federal assistance arrives. This report examines major cities’ (1) 

assessment of the risks of RDD and IND attacks and the extent to which 

they have developed plans for responding to them, (2) perceptions of

their abilities to respond to RDD and IND attacks in the first 24 hours 

(early response), and (3) perceptions of their need for federal support in 

the early response to RDD and IND attacks.

To conduct this work, we developed a questionnaire for the directors of 

emergency management of 31 major cities that DHS considers at highest 

risk for a terrorist act in fiscal year 2012. We were able to contact an 

emergency manager to receive the questionnaire in 29 of the 31 cities.14

We selected city emergency managers to receive the questionnaire 

because they are in the best position to provide a city-wide perspective 

on the level of preparedness to respond to RDD and IND attacks. 

Emergency managers from 27 of the 29 major cities that received our 

questionnaire responded for a response rate of 87 percent. This 

questionnaire asked city emergency managers to report on (1) how their 

city assessed the risk of RDD and IND attacks, and the availability of local 

response plans for these attacks; (2) their perceptions of their city’s ability 

to respond within the first 24 hours (early response); and (3) their 

perceptions of the need for federal support to prepare for and respond to 

these attacks. In addition, we reviewed federal guidance documents and 

other relevant reports. We also interviewed emergency managers or first 

responders in seven major cities selected for their geographic location 

and population size, and visited with emergency management planners 

who participated in an interagency IND response planning effort in 

Chicago. We also interviewed FEMA and NNSA emergency management 

planners, DOE national laboratory officials, and subject matter experts. 

We conducted these interviews to obtain information on the availability of 

federal technical and response assistance, initiatives to improve 

information and procedures, and the availability of federal funding to 

 14The 31 major cities supported by the fiscal year 2012 Urban Areas Security Initiative 

program are Anaheim, Atlanta, Baltimore, Boston, Charlotte, Chicago, Dallas, Denver, 

Detroit, Houston, Indianapolis, Kansas City, Las Vegas, Los Angeles, Miami, Minneapolis, 

Newark, New Orleans, New York City, Orlando, Philadelphia, Phoenix, Portland (OR), 

Riverside, San Antonio, San Diego, San Francisco, Seattle, St. Louis, Tampa, and the 

District of Columbia. We were unable to contact emergency managers in two cities, 

Atlanta and Newark.
Page 6 GAO-13-736 Nuclear Terrorism Response Plans

support preparedness efforts by major cities. Appendix I provides a more 

detailed description of our objectives, scope, and methodology. A copy of 

our questionnaire is found in appendix II.

We conducted this performance audit from June 2012 to September 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

This section provides information on the characteristics of RDD and IND 

attacks, major cities considered at high risk of terrorist act, core 

capabilities for all hazards preparedness, and response planning and 

associated federal guidance in the national preparedness system.

A radiological attack is defined as an event or series of events leading to 

the deliberate release, or potential release into the environment, of 

radioactive materials in sufficient quantity to require consideration of 

protective actions. Such an act would probably be executed with no 

advance warning. The typical means of dispersing radioactive material in 

an RDD is through a conventional explosion. There is a wide range of 

possible consequences from an RDD incident depending on the type and 

size of the device and the extent of dispersal. According to FEMA 

officials, the most likely RDD attack would impact a small area and not 

result in acutely harmful radiation doses to exposed individuals but could 

result in latent effects increasing the risk of cancer to exposed individuals. 

In contrast, an IND attack would produce a nuclear explosion from fissile 

material, which releases extreme heat and powerful shock waves, and 

disperses radiation that would be lethal for a significant distance. It also 

produces radioactive fallout, which would deposit radioactive material 

over a large area. If the fission of the radioactive material is not achieved, 

the effects of the explosion may resemble the impacts of an RDD. A 2011 

Congressional Research Service report states that the use of an RDD is 

more likely than an IND because the radioactive material to construct an 

RDD is more accessible, and it would be more difficult for a terrorist to 

Background

Characteristics of RDD 

and IND Attacks
Page 7 GAO-13-736 Nuclear Terrorism Response Plans

make an IND.15 In both cases, early response within the first hours 

includes initial actions to protect public health and welfare.

In 2003, DHS established an Urban Areas Security Initiative program to 

allocate homeland security grants to enhance and sustain the capacity to 

prevent, protect against, mitigate, respond to, and recover from acts of 

terrorism in high density urban areas, particularly the urban centers. The 

program identifies these high density urban areas by their major city. For 

example, the Chicago area includes 3 states, 14 counties, and 10 

principal cities. Figure 1 shows the 31 major cities in the Urban Areas 

Security Initiative program in fiscal year 2012 within the 10 FEMA regions.

 15Jonathan Medalia, “Dirty Bombs”: Technical Background, Attack Prevention and 

Response, Issues for Congress (Washington, D.C.: Congressional Research Service, 

June 24, 2011).

Major Cities Considered at 

High Risk of Terrorist 

Attack
Page 8 GAO-13-736 Nuclear Terrorism Response Plans

Figure 1: Major Cities at High Risk for Terrorist Attack by FEMA Region

In the National Preparedness Goal, DHS identified core capabilities 

needed for each of the five national preparedness mission areas. These 

core capabilities are considered necessary for an all hazards, capabilitybased approach to preparedness planning across all levels of 

government, although each level of government does not have to 

possess all capabilities. The five mission areas have in common three 

core capabilities—planning, public information and warning, and 

operational coordination—in addition to other capabilities specific to each 

mission area. For the response mission area, there are 11 additional core 

capabilities, for a total of 14. In compiling the list of core response 

Core Capabilities for All 

Hazards Preparedness
Page 9 GAO-13-736 Nuclear Terrorism Response Plans

capabilities, DHS based them on those capabilities that would be needed 

to respond to a large earthquake, major hurricane, and a weapon of mass 

destruction attack. Table 1 describes the activities for each of the 14 core 

capabilities in the response mission area that DHS considers necessary 

to save lives, protect property, and meet basic human needs after a 

catastrophic incident, such as an RDD or IND attack.

Table 1: Activities Associated with Each Core Capability for the Response Mission Area

Core capability Activities

Planning Conduct a systematic process engaging the whole community, as appropriate, in the 

development of executable strategic, operational, and/or community-based approaches to 

meet defined objectives.

Public Information and Warning Deliver coordinated, prompt, reliable, and actionable information to the whole community 

through the use of clear, consistent, accessible, and culturally and linguistically appropriate 

methods to effectively relay information regarding any threat or hazard and, as appropriate, 

the actions being taken and the assistance being made available.

Operational Coordination Establish and maintain a unified and coordinated operational structure and process that 

appropriately integrates all critical stakeholders and supports the execution of core 

capabilities.

Critical Transportation Provide transportation (including infrastructure access and accessible transportation services) 

for response priority objectives, including the evacuation of people and animals, and the 

delivery of vital response personnel, equipment, and services into the affected areas. 

Environmental Response/Health and 

Safety

Ensure the availability of guidance and resources to address all hazards including hazardous 

materials, acts of terrorism, and natural disasters in support of the responder operations and 

the affected communities.

Fatality Management Services Provide fatality management services, including body recovery and victim identification, 

working with state and local authorities to provide temporary mortuary solutions, sharing 

information with mass care services for the purpose of reunifying family members and 

caregivers with missing persons/remains, and providing counseling to the bereaved.

Infrastructure Systems Stabilize critical infrastructure functions, minimize health and safety threats, and efficiently 

restore and revitalize systems and services to support a viable, resilient community.

Mass Care Services Provide life-sustaining services to the affected population with a focus on hydration, feeding, 

and sheltering to those who have the most need, as well as support for reunifying families.

Mass Search and Rescue Operations Deliver traditional and atypical search and rescue capabilities, including personnel, services, 

animals, and assets to survivors in need, with the goal of saving the greatest number of 

endangered lives in the shortest time possible. 

On-scene Security and Protection Ensure a safe and secure environment through law enforcement and related security and 

protection operations for people and communities located within affected areas and also for all 

traditional and atypical response personnel engaged in lifesaving and life-sustaining 

operations.

Operational Communications Ensure the capacity for timely communications in support of security, situational awareness, 

and operations by any and all means available, among and between affected communities in 

the impact area and all response forces.
Page 10 GAO-13-736 Nuclear Terrorism Response Plans

Core capability Activities

Public and Private Services and 

Resources

Provide essential public and private services and resources to the affected population and 

surrounding communities, to include emergency power to critical facilities, fuel support for 

emergency responders, and access to community staples (e.g., grocery stores, pharmacies, 

and banks) and fire and other first response services.

Public Health and Medical Services Provide lifesaving medical treatment via emergency medical services and related operations 

and avoid additional disease and injury by providing targeted public health and medical 

support and products to all people in need within the affected area.

Situational Assessment Provide all decision makers with decision-relevant information regarding the nature and extent 

of the hazard, any cascading effects, and the status of the response.

Source: DHS, National Preparedness Goal, September 2011.

Under the national preparedness system, FEMA has issued guidance to 

help planners at all levels of government develop and maintain viable, all 

hazards emergency operations plans. This guidance describes how to 

develop and maintain emergency operations plans and how to implement 

these plans.16 While the basic emergency operations plan is oriented 

around an all hazards approach, FEMA guidance states that special 

policies may be necessary to respond to catastrophic incidents, such as 

an RDD or IND attack. According to FEMA guidance, local governments 

have the discretion to address these attacks in specific plans that are 

annexed to a city’s emergency operations plan, and the inclusion of these 

annexes will vary based on a jurisdiction’s assessment of the risks it 

faces. DHS guidance establishing the national preparedness system 

recognizes that since local governments will focus their planning efforts 

on the more likely risks, federal planning must complement these 

planning efforts for low-probability, high-consequence risks, such as a 

terrorist attack using an RDD or IND.17 DHS issued preliminary guidance 

for RDD and IND response planning to federal, state, and local 

governments in 2008, through a Federal Register announcement, that 

was followed in 2010 with additional federal guidance on responding to an 

IND attack.18 Some professional organizations have also published 

 16FEMA, Regional Planning Guide (Washington, D.C: March 2010), FEMA, Developing 

and Maintaining Emergency Operations Plans: Comprehensive Preparedness Guide 

(CPG) 101, Version 2.0 (Washington, D.C.: November 2010).

17DHS, National Preparedness System (Washington, D.C.: November 2011).

18DHS, “Planning Guidance for Protection and Recovery Following Radiological Dispersal 

Device (RDD) and Improvised Nuclear Device (IND) Incidents (73 Fed. Reg. 45-029 (Aug. 

1, 2008); and National Security Staff Interagency Policy Coordination Subcommittee for 

Preparedness & Response to Radiological and Nuclear Threats, Planning Guidance for 

Response to a Nuclear Detonation, Second Edition (Washington, D.C.: June 2010). 

Response Planning and 

Associated Federal 

Guidance
Page 11 GAO-13-736 Nuclear Terrorism Response Plans

guidance covering measures that state and local government should 

consider in responding to RDD and IND attacks.19 Figure 2 illustrates the 

conceptual response planning framework, including possible nuclear or 

radiological attack annexes as supplements to all hazards operational or 

emergency operations plans supporting national preparedness.

 19National Council on Radiation Protection and Measurements, Responding to a 

Radiological or Nuclear Terrorism Incident: A Guide for Decision Makers, Report No. 165 

(Bethesda, MD: 2010); Conference on Radiation Control Program Directors, Inc., 

Responding to a Radiological Dispersal Device: First Responder’s Guide—The First 12 

Hours (Frankfort, KY: September 2006); and Schoch-Spane, et al., Rad Resilient City: A 

Preparedness Checklist for Cities to Diminish Lives Lost From Radiation after a Nuclear 

Terrorist Attack (Baltimore, MD: Center for Biosecurity of UPMC, September 2011).
Page 12 GAO-13-736 Nuclear Terrorism Response Plans

Figure 2: Conceptual Response Planning Framework for Radiological Dispersal Device (RDD) and Improvised Nuclear Device 

(IND) Attacks within the National Preparedness System

Note: An alternative to supplementing an all hazards plan with a nuclear and radiological annex to 

account for changes in objectives and tasks might be to amend the all hazards plan itself.

a

DHS issued its first National Response Framework in 2008 that included emergency support 

functions, incident annexes, and the partner guides. A new response framework is under 

development.

b

FEMA is considering the need to revise the existing nuclear and radiological incident annex to the 

National Response Framework as an annex to a forthcoming FIOPs for the response and recovery 

mission areas.
Page 13 GAO-13-736 Nuclear Terrorism Response Plans

c

This plan is based on FEMA’s Regional Planning Guide, which outlines the means to implement the 

planning process consistent with FEMA’s Comprehensive Preparedness Guide (CPG) 101.

d

State governments have the option to develop specific plans that are annexed to their emergency 

operations plans based on their assessment of the hazard risk, such as a nuclear and radiological 

annex. As of 2012, all regional offices, states, and Urban Areas Security Initiative locations must use 

the Threat and Hazard Identification and Risk Assessment process.

e

This plan is based on FEMA’s Comprehensive Preparedness Guide (CPG) 101.

f

Local governments have the option to develop specific plans that are annexed to their emergency 

operations plans based on their assessment of the hazard risk, such as a nuclear and radiological 

annex. Local governments often use the Hazard Identification and Vulnerability Assessment process 

to develop their Hazard Mitigation Plans.

Many major city emergency managers, although not all, responded to our 

questionnaire that their city had assessed the risks of RDD and IND 

attacks and had ranked the risk of these attacks as lower than the risk of 

other hazards their city faces. The results of our questionnaire also show 

that fewer than half of the major cities that responded had developed 

specific RDD and IND response plans. Most of the major cities that 

reported having RDD and IND response plans also reported having 

conducted exercises to validate those plans.

Emergency managers of many of the major cities responding to our 

questionnaire reported that their city assessed the risk of RDD and IND 

attacks and ranked those risks as lower than other hazards their city 

faces. We asked emergency managers to refer to their city’s most 

recently completed Hazard Identification and Vulnerability Assessment,20

and report whether they assessed the risk of RDD or IND attacks and, if 

so, where those risks ranked relative to the other hazards assessed by 

their city, such as hurricanes, tornadoes, and flooding. All 27 cities 

responded to our question regarding their assessment of the risks of RDD 

and IND attacks. Three major cities reported that they had not completed 

 20According to FEMA officials and some city emergency managers we spoke with, the 

Hazard Identification and Vulnerability Assessment is also referred to as a Hazard 

Identification and Risk Assessment by some cities. They stated that both titles refer to the 

same type of document. Many of the major cities are adopting a new process, the Threat 

and Hazard Identification and Risk Assessment that FEMA requires its regional offices, 

states, and Urban Areas Security Initiative locations to use.

Many Major Cities 

Assessed the Risk of 

RDD and IND Attacks 

as Lower Than Other 

Hazards They Face, 

and Few Had 

Developed Specific 

Response Plans

Many of the Major Cities 

Assessed the Risk of RDD 

and IND Attacks as Lower 

Than Other Hazards
Page 14 GAO-13-736 Nuclear Terrorism Response Plans

a Hazard Identification and Vulnerability Assessment, or a similar 

assessment, and 6 cities reported that while they did have a recent 

assessment, they did not include either RDD or IND attacks in this 

assessment. Of the remaining 18 cities, 7 combined RDD and IND 

attacks into a single risk in their assessments, 9 assessed the risk of RDD 

and IND attacks separately, and 2 assessed the risk of an RDD attack but 

did not assess the risk of an IND attack. Of the 11 cities that assessed the 

risk of an RDD attack separately, 7 ranked the risk as lower than most or 

all other hazards their city faces. Of the 9 cities that separately assessed 

the risk of an IND attack, 7 ranked the risk as lower than most or all other 

hazards their city faces. In general, most cities that conducted a separate 

risk assessment for both RDD and IND reported that the risk of an RDD 

attack was higher than the risk of an IND attack. Table 2 shows the 

approach taken by the major cities responding to our questionnaire for 

assessing the risks of RDD and IND attacks, as well as the percentage of 

cities for each approach that ranked these risks lower than most or all 

other hazards they face. 

Table 2: Radiological Dispersal Device (RDD) or Improvised Nuclear Device (IND) 

Attack Risk Assessment Approach for 27 Major Cities and the Percentage Ranking 

These Hazards as Lower Than Other Hazards They Face

Cities assessing the hazard as lower than most or all other 

hazards they face

Type of hazard 

assessed Number Percentage 

RDD attack separately 7 of 11 cities that reported doing an assessment 

of an RDD attacka 64%

IND attack separately 7 of 9 cities that reported doing an assessment 

of an IND attack

78%

RDD/IND attacks 

combined

5 of 7 cities that reported doing an assessment 

of RDD/IND attacks combined 

71%

Source: GAO questionnaire results.

a

One of the 11 cities that separately assessed the risk of an RDD attack incorrectly skipped the 

question of where the risk of RDD attacks ranked relative to all other hazards their city faces.
Page 15 GAO-13-736 Nuclear Terrorism Response Plans

According to the responses to our questionnaire, fewer than half of the 

major cities have response plans21 that specifically address RDD and IND 

attacks, although some emergency managers indicated that their city had 

these plans in development. Of the 27 major cities that responded to our 

questionnaire, 11 (41 percent) of the emergency managers reported that 

their city had completed RDD response plans, and 8 (30 percent) had 

completed IND response plans. Some emergency managers for cities 

that did not have specific RDD and IND response plans reported that they 

would rely on other plans in the event of such an attack, including their 

city’s emergency operations plan or hazard management plan. Table 3 

identifies the extent to which major cities have hazard-specific RDD or 

IND response plans.

Table 3: Number and Percentage of 27 Major Cities with Specific Radiological 

Dispersal Device (RDD) or Improvised Nuclear Device (IND) Response Plans

Type of 

hazard

Hazard-specific 

plans 

completed

Hazard-specific 

plans in 

development

No hazardspecific plans 

completed or in 

development

Planning for 

this hazard is 

not-applicable

RDD 11 (41%) 6 (22%) 10 (37%) 0 (0%)

IND 8 (30%) 8 (30%) 10 (37%) 1 (3%)

Source: GAO questionnaire results.

Note: All 27 cities that responded to the questionnaire provided information on whether they had 

specific plans for RDD or IND attacks.

The questionnaire results regarding the number of cities with specific 

response plans for RDD and IND attacks are generally consistent with 

prior analyses conducted by FEMA. In 2010, FEMA conducted a national 

review of the contents of state and urban area emergency operations 

plans.22 FEMA found that more than 80 percent of urban areas reported 

that their emergency operations plans were well-suited to meet the 

challenges presented during large-scale or catastrophic incidents; 

however, fewer than half expressed confidence that specific RDD and 

 21In accordance with the National Incidence Management System, a response plan is to 

address the tactics and support activities required for the planned operational period, 

generally the first 12 to 24 hours after the event.

22FEMA, Nationwide Plan Review: Fiscal Year 2010 Report to Congress (Washington, 

D.C.: July 2010). FEMA reviewed emergency operations plans for 75 major cities, which 

include the 27 cities that responded to our questionnaire.

Fewer Than Half of Major 

Cities Have Specific 

Response Plans for RDD 

and IND Attacks
Page 16 GAO-13-736 Nuclear Terrorism Response Plans

IND response plans annexed to their emergency operations plans were 

adequate to manage such attacks. Forty percent of the urban areas had 

confidence in their RDD response plans, with 10 percent providing no 

response. Thirty percent said they had confidence in their IND response 

plans, with 20 percent providing no response.

Most emergency managers responding to our questionnaire who reported 

having specific RDD or IND response plans also reported having 

conducted exercises to validate those plans based on federal guidance. 

According to FEMA, a response plan should not be considered complete 

until exercises are conducted to validate it. Of the 11 cities that have 

specific RDD response plans, 9 of their emergency managers reported 

that their city had participated in RDD exercises from 2010 to 2012. Of 

the 8 cities that have specific IND response plans, 5 of their emergency 

managers reported that their city had participated in IND exercises over 

this same time period. These results are comparable to FEMA’s 2010 

national review of emergency operations plans that found that plans were 

frequently exercised. Specifically, 95 percent of all states and urban areas 

(including the major cities in our questionnaire) had conducted exercises 

using their basic plans, an increase from the previous review in 2006, and 

the response planning annexes subject to the most exercises included

those involving the response to the release of hazardous materials, which 

can include the dispersal of radioactivity from RDD and IND attacks.

Major city emergency managers responding to our questionnaire varied 

widely in their perception of their cities’ abilities to respond within the first 

24 hours (early response) to an RDD or IND attack. Limited DHS 

guidance exists that is applicable to major cities on the capabilities 

needed for early response to an RDD attack, but more such guidance 

exists for the early response to an IND attack. According to FEMA 

officials, the agency is considering developing additional guidance on 

nuclear and radiological incidents to be annexed to the forthcoming 

FIOPs for the response and recovery mission areas that may help guide 

the preparation of specific response plans to supplement the all hazards 

emergency operations plans of cities interested in doing so.

Most Major Cities That 

Have Specific RDD and 

IND Response Plans Have 

Also Exercised These 

Plans

Major Cities Vary 

Widely in Perceptions 

of Their Abilities to 

Respond within 24 

Hours of RDD and 

IND Attacks
Page 17 GAO-13-736 Nuclear Terrorism Response Plans

Our analysis of the questionnaire responses from major city emergency 

managers showed a wide variation in their perceptions regarding their 

cities’ abilities to respond within the first 24 hours to the RDD or IND 

attack depicted in the National Planning Scenarios, but most perceived 

that their city has more ability to conduct the early response for an RDD 

attack than for an IND attack. To gather this information, we obtained the 

emergency managers’ self-assessments of their cities’ abilities for early 

response to the national planning scenarios for RDD and IND attacks, but 

we did not ask them to assess their level of ability for each of the 14 

federal core response capabilities.23 We also asked them to consider 

mutual aid from other jurisdictions in estimating their early response 

abilities, but not to consider assistance from federal sources. Our analysis 

of emergency manager responses showed a wide variation in perceived 

early response abilities across the major cities. For example, 7 of 27 cities 

were perceived by their emergency managers as being able to conduct all 

of the activities needed for early response to an RDD attack without 

federal assistance—such as treating casualties—while 2 cities were 

perceived as being able to conduct all of the activities needed for an IND 

attack, without federal assistance. Moreover, all cities were perceived by 

their emergency managers as being able to conduct at least a few early 

response activities for an RDD attack, while 10 cities were perceived as 

not being able to conduct any early response activities for an IND attack. 

Overall, our analysis concluded that more emergency managers 

perceived that their city was able to conduct some, almost all, or all of the 

early response activities needed for an RDD attack (22 of 27 cities) 

compared with an IND attack (7 of 27 cities). Ten major cities reported not 

having any ability to conduct the early response after an IND attack, even 

considering assistance from the surrounding jurisdictions and their states, 

which would suggest a high expectation for federal assistance during 

early response. For RDD, emergency managers from 20 major cities 

reported perceiving that their city was not able to conduct all of the 

necessary early response activities, which may also suggest some 

expectation for federal assistance. Figure 3 shows the distribution of 

major cities among five categories of early response activities following 

an RDD or IND attack based on emergency manager perceptions of their 

city’s early response abilities including mutual aid from other jurisdiction 

but not federal assistance. 

 23This question requested a self-assessment because FEMA currently uses selfassessments to gauge local response capabilities and has not yet developed performance 

measures to determine actual levels of capability for incident response.

Major Cities Vary Widely in 

Perceptions of Their 

Ability to Respond within 

24 Hours of RDD and IND 

Attacks, but Perceive More 

Ability to Respond to an 

RDD Attack
Page 18 GAO-13-736 Nuclear Terrorism Response Plans

Figure 3: Amount of Perceived Early Response Ability of 27 Major Cities for Radiological Dispersal Device (RDD) and 

Improvised Nuclear Device (IND) Attacks

Note: Early response in an RDD or IND attacks refers to the abilities of major cities to respond to 

such an attack within the first 24 hours. The statements made by emergency managers of 27 cities 

regarding the response activities they would provide included mutual aid from their state, as well as 

surrounding jurisdictions, but not response assistance from the federal government.

The wide variation among emergency manager perceptions of their cities’

abilities to conduct the early response to RDD and IND attacks is not 

necessarily related to whether or not a city had specific response plans. 

Our analysis found that 10 of the 17 major cities perceived by their 

emergency managers as being able to conduct all or almost all the 

necessary response activities for an RDD attack did not have specific 

RDD response plans. For IND attacks, three of the four major city 

perceived by their emergency managers as able conduct all or almost all 

of the necessary response activities for an IND attack did not have 

specific IND response plans. Regarding the wide differences in 

emergency managers’ perceptions of their cities’ abilities to respond, 

FEMA officials told us that some cities will tend to overestimate the risks 

of an RDD attack due to their lack of understanding about dispersed 

radioactive material and underestimate their actual abilities to conduct 

responses across the federal core response capabilities. They told us that 

cities in states with nuclear power plants are likely to have a greater 
Page 19 GAO-13-736 Nuclear Terrorism Response Plans

understanding of the possible effects of a radiological attack and thus 

might be able to assess the risks and their cities’ abilities to respond 

better than other cities. These cities would have access to state technical 

and resource assistance developed and exercised to respond to a 

radiological dispersal incident at a nuclear power plant, which would have 

some characteristics of the dispersal of radioactive material by an RDD. 

Moreover, FEMA officials told us that cities closer to federal offices and 

facilities tend to have more interaction with FEMA and NNSA subject 

matter experts and are likely to have a greater understanding of the 

nature of an RDD attack. In regard to IND attacks, FEMA officials told us 

that they would expect that emergency managers would claim that such 

an attack would overwhelm their city response resources and that their 

city would need federal assistance across most federal core response 

capabilities.

DHS has provided limited guidance on the early response capabilities 

needed by cities for a large RDD attack based on the planning 

assumptions contained in the National Planning Scenarios, but more such 

guidance exists for the IND attack substantially based on the planning 

assumptions contained in the National Planning Scenarios. DHS has 

identified the core capabilities needed to respond to any catastrophic 

incident but generally not the specific capabilities needed by cities for 

early response to these attacks.24 DHS guidance contained in an annex 

to the 2008 National Response Framework25 states that an RDD or IND 

attack directed at a major city can have consequences that overwhelm 

the capabilities of state and local governments and may also seriously 

challenge existing federal response capabilities. In regard to RDD 

response, this DHS guidance states that major cities should be able to 

respond to small radiological releases with only occasional federal 

assistance but does not address the large RDD attack depicted in the 

National Planning Scenarios. According to FEMA and NNSA officials, 

 24 DHS, “Planning Guidance for Protection and Recovery Following Radiological Dispersal 

Device (RDD) and Improvised Nuclear Device (IND) Incidents” (73 Fed. Reg. 45-029, 

Aug. 1, 2008).

25DHS, “Nuclear/Radiological Incident Annex” to the National Response Framework

(Washington, D.C.: June 2008). According to a FEMA official, FEMA intends to replace 

this 2008 annex with the nuclear and radiological annex under consideration and, because 

this new annex will be more of an operational guide, it will be annexed to the all hazards 

FIOPs for the response and recovery missions. 

Limited Federal Guidance 

Available on Early 

Response Capabilities 

Needed by Major Cities for 

RDD Attacks, but More 

Available for IND Attacks
Page 20 GAO-13-736 Nuclear Terrorism Response Plans

additional federal guidance may not be necessary because they expect 

major cities to have the abilities to respond to a more likely smaller scale 

RDD attack than the large RDD attack, as they would a hazardous 

materials spill. If needed, the federal response to a hazardous materials 

release is described in an emergency support function covering oil and 

hazardous materials releases that is annexed to the National Response 

Framework.26 DHS has also issued guidance on protective actions that 

should be taken at various phases of response, including early response 

to the dispersal of radioactive materials, such in an RDD attack.27

However, the only detailed planning assumptions in current federal 

guidance for an RDD attack are those in the National Planning Scenarios

and this is for a large RDD attack.

28 DHS has not provided guidance on 

the early response capabilities needed by major cities for such an attack. 

According to NNSA officials, cities are likely to reach out for federal 

support in the case of either a large or small-scale RDD attack due to the 

rarity of the event and the high profile of any radiological emergency.

The federal government has issued more guidance pertaining to early 

response to an IND attack substantially based on the National Planning 

Scenario.29 In 2009, DHS issued an interim concept of operations plan for 

the federal response to the IND attack.

30 This federal operations plan 

states that the federal priority in the first 24 hours is to assist in saving 

lives and reducing casualties, while providing advice to those in the 

incident area to shelter in the nearest structure and listen for instructions 

from authorities. This federal operations plan also directs the states and 

 26DHS, Emergency Support Function #10—Oil and Hazardous Materials Response Annex 

to the National Response Framework (Washington, D.C.: May 2013).

27DHS, “Planning Guidance for Protection and Recovery Following Radiological Dispersal 

Device (RDD) and Improvised Nuclear Device (IND) Incidents” (73 Fed. Reg. 45-029, 

Aug. 1, 2008).

28The RDD attack depicted in the National Planning Scenario would contaminate 36 city 

blocks, causing 180 fatalities, 270 injuries, and 20,000 detectible contaminations, requiring 

10,000 people to seek shelters and prompting hundreds of thousands to self-evacuate in 

anticipation of future attacks.

29The IND attack depicted in the National Planning Scenario would contaminate up to 

3,000 square miles, causing hundreds of thousands casualties and damage up to a radius 

of .5 to 3 miles, requiring 100,000 people to seek shelter after being decontaminated and 

prompting 1 million to self-evacuate from the city.

30DHS, Interim IND CONPLAN: Federal Interagency Improved Nuclear Device Concept of 

Operations Plan, Version 10 (Washington, D.C.: Nov. 17, 2009).
Page 21 GAO-13-736 Nuclear Terrorism Response Plans

local governments to delineate control zones, coordinate evacuations, 

make shelter-in-place decisions, issue protective action 

recommendations, initiate decontamination procedures, and use the 

National Guard to assist with environmental monitoring, but it provides 

limited information on the capabilities needed to complete these actions. 

In 2010, a federal interagency task force issued planning guidance to all 

levels of government that expanded on the 2008 DHS planning guidance 

by addressing gaps in IND response, expanding the discussion of needed 

capabilities, and examining other IND scenarios beyond the one identified 

in the National Planning Scenario.31 This 2010 guidance presents general 

background information that builds a foundation for specific planning 

recommendations on response to an IND attack during the first 24 to 72 

hours prior to the arrival of significant federal resources. This guidance 

states that other recommendations would be forthcoming, such as for 

establishing critical communications among first responders. This

guidance recognizes that response planning must be done on a cityspecific basis using city-specific impact assessments.32 However, this

guidance also points out that response to an IND will largely be provided 

from neighboring jurisdictions, which would require advanced planning to 

establish mutual aid and response protocols. Notwithstanding the specific 

planning recommendations, the 2010 planning guidance does not detail 

the early response capabilities needed by major cities to an IND attack in 

relation to other sources of assistance. Without greater awareness of and 

additional federal guidance on the capabilities needed by cities for early 

response to both RDD and IND attacks, cities may not have the 

information they need to adequately prepare for and respond to them. 

Any gaps in response capabilities could lead to complications that result 

in greater loss of life and economic impacts. Figure 4 provides a simple 

illustration of the capability requirements for increasing levels of incident

effects, with an IND attack likely to be the highest level of incident effect.33

 31National Security Staff, DHS, Planning Guidance for Response to a Nuclear Detonation, 

Second Edition (Washington, D.C. Interagency Policy Coordinating Subcommittee for 

Preparedness & Response to Radiological and Nuclear Threats, June 2010).

32 Planning guidance recommendations were provided for consideration by emergency 

planners within the first days after an IND attack for 1) shelter and evacuation, 2) medical 

care, 3) population monitoring and decontamination, and 4) emergency public information.

33GAO, Managing Preparedness Grants and Assessing National Capabilities: Continuing 

Challenges Impede FEMA’s Progress, GAO-12-526T (Washington, D.C.: Mar. 20, 2012).
Page 22 GAO-13-736 Nuclear Terrorism Response Plans

Figure 4: Anticipated Capability Requirements by Response Time

FEMA is considering the need to develop a nuclear and radiological 

annex, as depicted in figure 2, to help guide federal response activities 

and possibly assist in the development of specific response plans for 

RDD and IND attacks as supplements to city emergency operations 

plans. This federal nuclear and radiological annex would be attached to 

the forthcoming FIOPs—currently under review for approval—for the all 

hazards planning framework for the response and recovery mission 

areas. FEMA officials told us that a nuclear and radiological annex may 

be needed to supplement these FIOPs because their all hazards 

orientation would not address several unique requirements and concepts 

of operations specifically tailored to the needs for nuclear and radiological 

incidents. The need for such an annex is also supported by a 2012 DHS 

report that found the response and recovery needs after a radiological 

attack differ from traditional all hazards incidents due to the need for 

FEMA Is Considering 

Developing Additional 

Guidance for Response to 

RDD and IND Attacks That 

May Help Guide 

Development of Specific 

Response Plans by Major 

Cities
Page 23 GAO-13-736 Nuclear Terrorism Response Plans

decontamination activities, heightened public anxiety, long-term risk 

management, and substantial disruption to citizen’s lives and the 

economy.

34 FEMA officials said that if they decide to develop a nuclear 

and radiological annex it could help guide adjustments to FEMA regional 

operational plans. They also told us that these adjustments to the regional 

operational plans may help encourage major cities in FEMA regions to 

develop annexes to their all hazards emergency operations plans 

covering specific RDD and IND response plans.

FEMA has not determined what it might include in the nuclear and 

radiological annex or how to address RDD and IND response planning. 

FEMA officials told us that this annex is expected to address RDD and 

IND attacks, as well as a broader spectrum of radiological dispersal 

incidents, such as nuclear power plant accidents. According to FEMA 

guidance, separate hazards can be grouped under a more general 

category, such as terrorist acts, but FEMA recognizes that problems can 

arise that will affect subsequent analysis when grouping hazards with a 

wide range of consequences under a single category, such as might be 

the case with RDD and IND attacks.35 FEMA officials provided information 

to compare the characteristics of RDD and IND attacks, as shown in table 

4. One of the characteristics is the magnitude of the RDD and IND 

attacks. FEMA officials told us that if they decided to develop the nuclear 

and radiological annex, they would also consider the need to clarify the 

planning assumptions for these incidents, particularly the RDD attack 

scenario.

 34DHS, Response and Recovery Knowledge Product: Key Planning Factors for Recovery 

from a Radiological Terrorism Incident (Washington, D.C.: September 2012).

35 FEMA, Developing and Maintaining Emergency Operations Plans: Comprehensive 

Preparedness Guide (CPG) 101, Version 2.0 (Washington, D.C.: November 2010).
Page 24 GAO-13-736 Nuclear Terrorism Response Plans

Table 4: Comparison of Characteristics of Radiological Dispersal Device (RDD) and

Improvised Nuclear Device (IND) Attacks

Categories RDD characteristics IND characteristics

Magnitude Small scale destruction with 

wide range of possible 

magnitudes across city 

blocks with few deaths

Large-scale destruction 

affecting the entire 

metropolitan area with 

thousands of deaths

Time sensitivity Right early decisions can 

reduce social and economic 

impacts

Right early decisions can 

save lives

Radioactive exposure risk Limited number of people 

exposed to higher doses of 

radiation in various ways 

depending on the radioactive 

material

Large number of people 

having acute exposure in 

blast zone with widespread 

exposure to significant and/or 

lethal levels of radiation 

primarily downwind from 

fallout through gross 

exposure

Immediate health effects Possible latent effects from 

radiation exposure

Immediate acute and latent 

effects from radiation 

exposure

Protective Actions Avoid surfaces that have 

been contaminated

Shelter in buildings that have 

higher protection from 

radiation exposure

Source: GAO from FEMA information.

An additional FEMA consideration in developing the nuclear and 

radiological annex to the FIOPs is the information recently gained from 

the agency’s participation in a multigovernmental initiative to develop an 

IND regional operations plan for Chicago, which is intended to guide 

development of other regionally based IND operations plans.36 For 

example, FEMA found that the development of this IND regional 

operations plan provided information on needed early response 

capabilities, coordination of stakeholder groups, the type and timing of 

federal assistance, and the level of effort to complete the plan. The IND 

planning team determined that the most feasible course of action to save 

the greatest number of lives during early response involved concentrating 

on a limited number of activities around public information and warning,

operational coordination and communications, on-scene security and 

protection, situational assessment, and shelter-in-place and evacuation. 

 36FEMA, Improvised Nuclear Device Regional Operations Plan: Region V, State of Illinois, 

and City of Chicago Operations Plan (Chicago, IL: June 2012).
Page 25 GAO-13-736 Nuclear Terrorism Response Plans

These activities are covered by 7 of the 14 federal core response 

capabilities in the national preparedness goal. In addition, IND planning 

team members told us that the planning effort gave them a greater 

appreciation of the communication and coordination activities needed 

across stakeholder groups to respond to an IND attack. The planning

effort involved more than 300 local, state, and federal emergency 

management offices and private entities. Moreover, the IND planning 

team was able to develop a detailed spreadsheet containing the type and 

timing of assistance that might be available and needed—at the three 

response phases—for an IND attack on Chicago. The development of the 

plan has taken time and substantial funding. The IND planning process 

has been under way since 2010, costing about $7.6 million, as of 2012, 

when the plan was completed. This cost includes the project work of the 

city, the state of Illinois, neighboring states, and federal agencies that 

contributed to the development of the overall plan. 

As a result of the IND planning effort in Chicago, FEMA officials told us 

that they plan to use the information gained to assist other major cities 

seeking to develop similar operations plans with regional partners. FEMA 

officials told us that they also plan to undertake this planning initiative in 

Boston, the District of Columbia, and Houston during fiscal year 2013, 

with planning initiatives in Los Angeles, New York and Philadelphia to 

follow. In addition, FEMA officials told us that they plan to look for 

geographic and infrastructure similarities, such as common building 

structures and transportation systems in each region in order to expedite 

the planning process and reduce planning costs for other cities in a 

region. FEMA’s Response Planning Division has allocated about $3.8 

million for IND planning activities for fiscal year 2013. FEMA officials also 

told us that they thought that an IND response plan would be sufficient to 

address most of the response needs after an RDD attack as well.

Emergency managers of major cities responding to our questionnaire 

reported varying levels of need for federal support in early response to 

RDD and IND attacks in the form of technical and resource assistance, 

procedures and information for early response activities, and 

preparedness funding. Emergency managers identified a number of areas 

for federal technical and resource assistance, but we found limitations in 

the federal guidance applicable to major cities on the type and timing of 

this assistance. Emergency managers of major cities also reported the 

need for federal government research that could improve procedures and 

information for their early response to RDD and IND attacks. DHS has 

supported working groups of subject matter experts to help mitigate 

Most Major Cities 

Expressed Need for 

Federal Support for 

Early Response to 

RDD and IND Attacks
Page 26 GAO-13-736 Nuclear Terrorism Response Plans

shortcomings in response capabilities for IND attacks, which may have 

applications for improving RDD response capabilities. In addition, 

emergency managers reported that a decrease in federal funding would 

affect their abilities to conduct early response to RDD and IND attacks.

Most emergency managers from major cities responding to our 

questionnaire reported that they need federal technical and resource 

assistance to support their early response to RDD and IND attacks, but 

federal guidance on the type and timing of this assistance is not found in 

a single document and may not be well understood by emergency 

managers. Nineteen of 27 emergency managers perceive a need for 

federal technical and resource assistance for early response to an RDD 

attack, and 21 of them perceive a need for this assistance in early 

response to an IND attack. Our analysis of questionnaire responses 

determined that of the 14 core response capabilities, emergency 

managers indicated that the capability most needing federal technical and 

resource assistance for both RDD and IND attacks (11 of 27 cities each) 

was situational assessment. Situational assessment provides decision 

makers with technical information such as the nature and extent of the 

hazard, its cascading effects, and the status of the response. For RDD 

attacks, after situational assessment, the emergency managers’ next 

most frequently cited federal assistance needs were the following:

• public health and medical services (8 of 27 cities),

• operational coordination (5 of 27 cities), and

• on-scene security and protection (5 of 27 cities).37

For IND attacks, after situational assessment, the emergency managers’

next most frequently cited federal assistance needs were as follows:

• on-scene security and protection (5 of 27 cities), and

• public health and medical services (5 of 27 cities).

We also obtained several responses from emergency managers 

regarding actions, such as planning, that the federal government should 

take to help sustain and improve early response capabilities. For 

 37Public health and medical services provide lifesaving medical treatment and provide 

support and products to avoid additional disease and injury. Operational coordination 

establishes and maintains a unified and coordinated operational structure. On-scene 

security and protection ensures a safe and secure environment through law enforcement 

and other operations.

Major Cities Reported 

Need for Guidance on the 

Type and Timing of 

Federal Technical and 

Resource Assistance for 

Early Response to RDD 

and IND Attacks
Page 27 GAO-13-736 Nuclear Terrorism Response Plans

example, one emergency manager commented that integrated RDD and 

IND plans of local, state, and federal government roles and 

responsibilities are nonexistent. Another emergency manager stated that 

that the federal government should provide a model RDD and IND 

response plan and templates to assist local jurisdictions’ efforts.

The type and timing of federal assistance to major cities during the early 

response to an RDD or IND attack may not be well understood by all 

major city emergency managers, even though some guidance is available

but in different documents. For example, in 2008, DHS issued guidance 

on federal agency responsibilities for responding to incidents involving the 

release of nuclear, radiological, and hazardous materials in the National 

Response Framework, and introduced the concept of phases of response 

in planning guidance for RDD and IND attacks. However, these and other 

guidance documents do not contain complete information on the type and 

timing of federal technical and resource assistance by response phases. 

For RDD attacks, DHS has not provided specific operational guidance on 

the type and timing of federal assistance that might be made available to 

cities for early response, although some information is available in an 

emergency support function annex to the National Response Framework. 

For IND attacks, DHS identified the technical and resource activities that 

federal agencies could provide to respond to an IND attack in a 2009 

federal interim concept of operations plan and more recently in the 2012 

IND regional operations plan for Chicago. In addition, federal agencies 

have provided various descriptions of the type and timing of the federal 

assistance that might be available on their websites. However, FEMA 

officials told us that the type and timing of the federal response would 

depend on the proximity of the city to federal offices. Confusion over the 

type and timing of assistance, such as federal assistance in the case of 

an IND attack, could produce a disjointed and untimely early response to 

the attack that might increase its consequences.

Based on information from a variety of sources, some of which may not 

be readily available to major cities, we developed an illustration of the 

federal agencies most likely to assist these cities during early response 

with activities associated with the core capabilities they claim they can 

support after an IND attack. While other federal agencies are involved 

through their emergency support functions under the National Response 

Framework, a senior FEMA official told us that the four federal agencies 

we identified in figure 5 would be the most involved during the first 24 

hours after an IND attack. Figure 5 provides an illustration of the federal 

technical and resource support for the core capabilities necessary for 

major city early response to an IND attack. 
Page 28 GAO-13-736 Nuclear Terrorism Response Plans

Figure 5: Anticipated Federal Technical and Resource Support for Core Capabilities Necessary for a Major City Early 

Response to an Improvised Nuclear Device (IND) Attack
Page 29 GAO-13-736 Nuclear Terrorism Response Plans

Note: This figure includes the four major agencies (DOE/NNSA, DHS/FEMA, HHS, and DOD) that 

would have primary responsibility for providing technical and resource assistance to a major city

within the first 24 hours after an IND attack, although other federal agencies may be present. The 

need for core response capabilities from the federal government may differ for an RDD attack. This 

figure is based on our review of documents, such as DHS, Emergency Support Functions Annex to 

the National Response Framework (2008), DHS, Federal Interagency Improvised Nuclear Devices 

Concept of Operations Plan (2009), FEMA, IND Regional Operations Plan for Chicago (2012), and 

interviews with FEMA and NNSA officials.

Most emergency managers responding to our questionnaire indicated that 

their cities perceive a need for federal government research that could 

improve procedures or information for their early response to RDD and 

IND attacks. Using DHS guidance, we developed a list of 10 topic areas 

for federal government research initiatives that could improve procedures 

or information used by cities during the first 24 hours after the detonation 

of an RDD or IND.38 We asked emergency managers for their opinions on 

how much impact, if any, each topic area might have on improving their 

city’s capability for early response to an RDD or IND attack. For example, 

emergency managers from two-thirds of the major cities (18 of 27 cities) 

identified communicating a sheltering-in-place strategy to the public and 

communicating potential impacts of radiation exposure to the public as 

the topic areas having the highest impact. Figure 6 shows emergency 

managers’ responses identifying the topic areas their city considers 

important for improving procedures or information necessary for early 

response to RDD and IND attacks.

 38We developed the list of current federal IND focus areas from the following two DHS reports: DHS,

DHS Strategy for Improving the National Response and Recovery from an IND Attack (Washington, 

D.C.: March 24, 2010) and DHS, Improvised Nuclear Device Response and Recovery CapabilityBased Implementation Plan: Methods, Plans, and Projects for Addressing the Capability Gaps 

Identified in the DHS Strategy for Improving the National Response and Recovery from an IND Attack

(Washington, D.C.: March 2012), and the Executive Office of the President, National Science and 

Technology Council, Nuclear Defense Research and Development Roadmap, Fiscal Years 2013-

2017 (Washington, D.C.: April 2012).

Major Cities Reported 

Need for Improved 

Procedures and 

Information for Early 

Response to RDD and IND 

Attacks
Page 30 GAO-13-736 Nuclear Terrorism Response Plans

Figure 6: Federal Radiological Dispersal Device (RDD) or Improvised Nuclear 

Device (IND) Response Topic Areas Identified by Major City Emergency Managers 

as Needed to Improve Early Response Capabilities

Note: GAO received questionnaire responses from emergency managers of 27 major cities: Anaheim, 

Baltimore, Boston, Charlotte, Chicago, Dallas, Denver, Detroit, Houston, Indianapolis, Kansas City, 

Las Vegas, Los Angeles, Miami, Minneapolis, New Orleans, New York City, Orlando, Philadelphia, 

Portland, Riverside, San Diego, San Francisco, Seattle, St. Louis, Tampa, and the District of 

Columbia.

We compared the emergency managers’ responses on the impact that 

improved procedures and information might have on their city’s early 

response to RDD and IND attacks with the research initiatives being 

considered by six FEMA IND focus working groups to determine if they 

align. FEMA has established these working groups of subject matter 

experts to mitigate shortcomings in response capabilities for an IND 
Page 31 GAO-13-736 Nuclear Terrorism Response Plans

attack, such as clarifying responsibilities and coordinating efforts among 

government levels and federal agencies.39 We found that the areas 

addressed by the working groups through their initiatives are generally 

the same as those topic areas emergency managers reported as having a 

high impact on procedures and information needed for early response to 

an RDD and IND attack.

FEMA does not have current plans to identify or attempt to fill potential 

gaps in capabilities for early response specifically to an RDD attack. 

However, IND focus area working group experts and a senior FEMA 

official told us that their efforts to fill gaps in IND capabilities and all 

hazards plans would have application for other catastrophic hazards, 

including RDD attacks. For example, they told us that RDD and IND 

attacks share some common attributes, such as (1) the release of 

radiological materials, (2) the need for decontamination and radiation 

treatment, and (3) prioritization of response resources and personnel 

based on ethical, philosophical, legal, and practical decision tools. In 

addition, both types of attacks also require communication of consistent 

information about radiation effects on general health outcomes and 

protective measures. Further, NNSA officials told us they also have 

several programs that might apply to RDD, as well as IND planning and 

capability enhancements.

Most emergency managers responding to our questionnaire indicated that 

their cities need federal funding to maintain current early response 

capabilities to an RDD or IND attack. Almost all emergency managers (24 

of 27 cities for RDD and 23 of 27 cities for IND) indicated that their city

needs federal funding to maintain current early response capabilities. 

According to the 2008 National Response Framework, response 

capabilities are developed within the national preparedness system 

through effective planning, coordinating, training, equipping, and 

exercising activities. These activities are essential elements of an 

integrated, capability-based approach to preparedness. Emergency 

 39The six IND focus area working groups are the Manage the Response, Crisis Decisionmaking, Communications and Public Messaging, Scientific Support, Public Health and 

Medical, and Recovery. Multiple federal agencies participate in these focus area working 

groups along with members from state and local emergency management offices and first 

responders (fire, police, emergency medical services, and public work officials). 

Nongovernment organizations such as medical practitioners, ethicists, clergy, biologists, 

sociologists, and university and private industry representatives also participate.

Major Cities See Need for 

Federal Funding to 

Maintain Early Response 

to RDD and IND Attacks
Page 32 GAO-13-736 Nuclear Terrorism Response Plans

managers reported that a decrease in federal funding would affect the 

degree to which each of these activities builds the capabilities needed for 

early response to an RDD or IND attack. Our analysis of questionnaire 

results indicated that about a third of 27 cities identified equipment, 

training, and planning activities important to the capabilities that would be 

most affected by a decrease in federal preparedness funding, with fewer 

cities indicating that coordination and exercising would be affected.

Federal funding to support preparedness against terrorist attacks and 

other catastrophic incidents such as RDD and IND attacks currently 

comes from seven DHS grant programs.40 In fiscal year 2013, DHS 

allocated more than $1.5 billion for these seven grant programs, but 

officials in charge of these programs were unable to determine how much 

of the funding was used by major cities to improve early RDD and IND 

response capabilities.41 Two of the DHS grant programs that have been 

most relevant to response preparation for an RDD or IND attack are the 

Homeland Security Grant Program and the temporary (fiscal years 2008 

to 2011) Regional Catastrophic Planning Grant Program. In fiscal year 

2013, DHS allocated more than $968 million to the Homeland Security 

Grant Program, and more than half (roughly $560 million) was allocated 

to Urban Areas Security Initiative grants, a portion of which goes to law 

enforcement terrorism prevention activities. The Regional Catastrophic 

Planning Grant Program awarded $14 million in grants in fiscal year 2011, 

the last year it made awards, to support regional planning efforts to 

address catastrophic incidents.42 For example, these funds were used by 

 40The seven DHS grant programs are the Homeland Security Grant Program, Emergency 

Management Performance Grants Program, Tribal Homeland Security Grant Program, 

Nonprofit Security Grant Program, Intercity Passenger Rail (Amtrak) Program, Port 

Security Grant Program, and the Transit Security Grant Program. From fiscal years 2002 

through 2011, the federal government appropriated over $37 billion to DHS’s 

preparedness grant programs to enhance the capabilities of state and local governments 

to prevent, protect against, respond to, and recover from terrorist attacks.

41FEMA could query its Biannual Strategy Implementation Report database to determine 

the level of funding used for the general category of chemical, biological, radiological, 

nuclear, and explosives.

42From 2007 through 2011 the Regional Catastrophic Planning Grant Program provided 

more than $147 million in funding. The Regional Catastrophic Preparedness Grant 

Program Comprehensive Report, February 2012 lists 10 sites as receiving this funding 

including the San Francisco Bay Area, Boston, Chicago, Hampton Roads (24 jurisdictions 

in southeast Virginia and northeast North Carolina), Honolulu, Houston, Los Angeles, the 

National Capital Region, New York/New Jersey/Connecticut/Pennsylvania, and the Puget 

Sound region (8 Washington state counties and their associated cities).
Page 33 GAO-13-736 Nuclear Terrorism Response Plans

New York and New Jersey to develop RDD and IND response plans and 

were also combined with other federal funding to support development of 

the IND regional operations plan for Chicago. According to members of 

the IND planning team for Chicago, the Regional Catastrophic Planning 

Grant Program provided the funding to bring together the many 

stakeholder groups that would be involved in responding to an IND attack 

and, without continued funding, it would be difficult to maintain the same 

level of collaboration. Appendix III provides a detailed breakdown of the 

seven federal grant programs for fiscal year 2013.

DHS has recognized that the early response to catastrophic incidents 

such as an RDD or IND attack on a major city is critical and has to come 

first from the city and surrounding jurisdictions. While cities are assumed 

to be preferred targets for an RDD or IND attack, in response to our 

questionnaire, many emergency managers indicated that their cities 

ranked the risk of these attacks as lower than other hazards their cities 

face, and fewer than half of the cities have specific response plans for 

such attacks. City emergency managers rely on federal guidance to 

prepare all hazards emergency operations plans and also specific 

response plans for hazards of concern that can be annexed to these 

emergency operations plans at the discretion of the city. However, we 

found limitations in the federal planning guidance applicable to the early 

response capabilities needed by cities for an RDD attack of the size 

depicted in the National Planning Scenarios. More federal planning 

guidance applicable to major cities has been developed for IND response, 

primarily based on the event depicted in the National Planning Scenarios,

but this guidance does not detail the early response capabilities needed 

by major cities in relation to other sources of assistance. Perceptions of 

emergency managers varied widely on their cities’ abilities to conduct the 

activities needed for early response to the type of RDD attacks described 

in the National Planning Scenarios—with assistance from surrounding 

jurisdictions but not the federal government—from being able to conduct 

all activities for early response to being able to conduct few early 

response activities. Less variation was evident for perceived early 

response abilities to an IND attack—considering this same source of 

assistance—with many cities indicating that such an attack would 

overwhelm their response abilities. Most cities indicated the need for 

federal technical and resource assistance—among other areas of federal 

support—for early response to RDD and IND attacks, but we found that 

complete guidance on the type and timing of this assistance is not readily 

available in a single document and is not well understood by all major city 

emergency managers. Any confusion over the type and timing of federal 

Conclusions
Page 34 GAO-13-736 Nuclear Terrorism Response Plans

assistance could produce a disjointed and untimely early response to an 

attack that might increase its consequences. Without greater awareness 

of existing federal guidance and continued actions to close gaps in the 

guidance applicable to cities’ early response to RDD and IND attacks, 

some cities may not have the information they need to adequately 

prepare for and respond to them. Lack of adequate response planning 

could lead to complications that result in greater loss of life and economic 

impacts.

To provide assistance to major cities in planning for early response to 

RDD and IND attacks, we recommend that the Secretary of Homeland 

Security direct the Administrator for the Federal Emergency Management 

Agency to promote greater awareness of existing federal guidance and 

develop additional guidance where appropriate to clarify the capabilities 

needed by cities for these attacks, including the planning assumptions for 

an RDD attack and the type and timing of federal assistance for early 

response.

We provided a draft of this report to DHS and to DOE through NNSA for 

review and comment. DHS did not concur with our recommendation and 

provided written comments, which are reproduced in appendix IV. In 

addition, in an e-mail received August 27, 2013, the Director, Audit 

Coordination and Internal Affairs Office of Management and Budget (NAMB-1.1) for NNSA stated that as the recommendations in the report are 

directed to DHS and FEMA, NNSA would not be preparing a formal 

response. DHS and NNSA provided technical comments, which we 

incorporated as appropriate.

In the comment letter, DHS states that FEMA program officials and 

subject matter experts are concerned that our survey may have resulted 

in the receipt of skewed data and information that affected our analysis 

and conclusions. For example, the letter stated that some respondents 

may have believed that an IND/RDD event would or could be fully 

handled at the local level and therefore provided inputs partial toward 

taking on an inordinate level of responsibility. They also stated that our 

recommendation runs contrary to the survey results which illustrate a 

trend of grouping RDD and IND attacks for analysis and planning. We 

disagree. Our questionnaire explicitly asked city emergency managers to 

consider response assistance from surrounding jurisdictions in their 

assessment of response abilities, and only exclude federal assistance. In 

this way, we were able to isolate the perceived need for federal support, 

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
Page 35 GAO-13-736 Nuclear Terrorism Response Plans

which we found for technical and resource assistance, improved 

procedures and information, and funding. Further, emergency managers 

did not provide trend information through their questionnaire responses 

on assessing RDD and IND risks, and cities more often separated the 

assessment of RDD and IND risks than combined them as DHS indicated 

in its comment letter. In addition, we took a number of steps to develop 

the questionnaire and to identify the best source for a response. For 

example, we conducted extensive pretesting and obtained comments on 

a draft questionnaire from officials at FEMA’s National Preparedness 

Assessment Division. We also determined that city emergency managers 

were in the best position to provide a city-wide perspective on this issue, 

but we allowed them to seek advice from other city officials as necessary.

In its comment letter, DHS stated that neither the department nor FEMA 

believes that our recommendation that FEMA develop additional 

guidance in a single document to clarify the capabilities needed by cities 

for these attacks, including the planning assumptions for an RDD attack 

and addressing the type and timing of federal assistance for early 

response takes into sufficient account advances made to the 

preparedness system. In addition, the comment letter states that FEMA 

program officials and subject matter experts believe the recommendation 

does not align with our survey results or all-hazard risk management for 

worst case catastrophic scenarios. It also states that FEMA has concerns 

with the report’s characterization of the nation’s ability to respond to a 

nuclear and/or radiological attack. Furthermore, the letter states that 

additional RDD response guidance in a single document would be 

counterproductive to the existing planning and guidance structure for IND 

and all hazards incidents. As we note in the report, FEMA is already 

considering development of a nuclear and radiological incident annex to 

the FIOPs for the response and recovery mission areas based on the 

recognition that the all hazards approach may be insufficient to cover the 

unique response needs for nuclear and radiological incidents. While our 

recommendation did not specify how FEMA should provide this additional 

guidance, we have added language to the recommendation to clarify that 

that we are not recommending a single guidance document to cover only 

RDD response. In addition, to address the DHS/FEMA concern that city 

emergency managers may not be fully informed about available 

guidance, we added language to the recommendation for FEMA to 

promote greater awareness of existing federal guidance.

More generally, DHS’ comment letter states that FEMA officials do not 

believe we provided adequate context for the National Preparedness 

System as defined by Presidential Policy Directive 8, which may cause 
Page 36 GAO-13-736 Nuclear Terrorism Response Plans

confusion for cold readers not familiar with how the directive has been 

implemented. In addition, the comment letter states that the operational 

frameworks, structures, and ongoing efforts that have been developed in 

support of the directive’s comprehensive approach to national response 

are not fully outlined in the report; specifically, the letter states that the 

Nuclear and Radiological Incident Annex to the National Response 

Framework and Emergency Support Functions as the nation’s 

coordinating structures are not accurately portrayed and cites figure 5 as 

an inaccurate and misleading depiction of the federal response for an 

IND/RDD event. While the purpose of this report was not to conduct a 

detailed assessment of federal guidance or implementation of the 

directive, we added additional information about FEMA’s leadership role 

in coordinating the federal response to nuclear and radiological incidents 

within the context of the National Response Framework and its efforts to 

develop IND response planning guidance. We also added that the 

illustration in figure 5 of federal agency support for core response 

capabilities that might be available to cities during the first 24 hours after 

an IND attack does not include all federal agencies’ activities but only 

those four agencies confirmed by a senior FEMA official as being most 

present during this time period.

We are sending copies of this report to the Secretary of Homeland 

Security and the Secretary of Energy, the appropriate congressional 

committees, and other interested parties. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202)512-3841 or trimbled@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made contributions to this 

report are listed in appendix V.

Sincerely yours,

David C. Trimble

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-13-736 Nuclear Terrorism Response Plans

In our review, we examined major cities’ (1) assessment of the risks of 

RDD and IND attacks and the extent to which they have developed plans 

for responding to them, (2) perceptions of their abilities to respond to 

RDD and IND attacks in the first 24 hours (early response), and (3) 

perceptions of their need for federal support in the early response to RDD 

and IND attacks. To address these questions we sent a questionnaire to 

major city emergency managers, and we conducted interviews with 

outside experts and federal, state, and local officials.

To gather information from major U.S. cities relevant to all three of our 

objectives, we developed a questionnaire for the directors of emergency 

management for each of the 31 major cities that were in the Urban Areas 

Security Initiative (UASI) program in fiscal year 2012.1 We chose the 

major cities within each UASI region because in our document review, as 

well as in interviews with the Federal Emergency Management Agency 

(FEMA), UASI regions were identified as higher risk jurisdictions for 

terrorist acts, including those using RDDs or INDs.2 As FEMA guidance 

states that local jurisdictions should plan and develop capabilities to 

respond to incidents based on risk, these jurisdictions are in need of 

developing plans and preparing for the response to RDD and IND attacks. 

Each of the 31 UASI locations covers a large metropolitan area that 

includes many local governments. For example, the Chicago UASI 

includes 3 states, 14 counties, and 10 principal cities. It did not serve our 

purpose to send the questionnaire directly through the UASI structure 

itself as the number of jurisdictions involved could introduce issues of 

reliability in the answers, as well as consistency in terms of the process 

used by each UASI to fill out our questionnaire. FEMA officials told us that 

the largest metropolitan area within each UASI constitutes the area at the 

highest risk for attack in each jurisdiction. In addition, we selected city 

emergency managers to receive the questionnaire because they were in 

the best position to provide a city-wide perspective on the level of 

preparedness to respond to RDD and IND attacks. Therefore, we chose 

to send questionnaires to only the emergency managers of these large 

metropolitan areas. The emergency management offices in Atlanta and 

 1

The 31 major cities in the UASI program in fiscal year 2012 were Anaheim, Atlanta, 

Baltimore, Boston, Charlotte, Chicago, Dallas, Denver, Detroit, Houston, Indianapolis, 

Kansas City, Las Vegas, Los Angeles, Miami, Minneapolis, Newark, New Orleans, New 

York City, Orlando, Philadelphia, Phoenix, Portland (OR), Riverside, San Antonio, San 

Diego, San Francisco, Seattle, St. Louis, Tampa, and the District of Columbia.

2

The questionnaire is reproduced in full in appendix II.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-13-736 Nuclear Terrorism Response Plans

Newark did not respond to our contact attempts, so we sent out 

questionnaires to the 29 cities that did reply. In developing our 

questionnaire, we developed questions that addressed all three of the 

report objectives and had these reviewed both internally, as well as by 

staff of FEMA’s National Preparedness Assessment Division. We 

conducted seven cognitive pretests with emergency management officials 

and first responders from major cities selected for their geographic 

location and population size in order to minimize errors that might occur 

from respondents who interpreted our questions differently than we 

intended. During these pretests, we also interviewed these emergency 

management officials and first responders to gain additional context 

regarding their city’s preparedness for responding to either an RDD or 

IND attack.

The questionnaire was implemented as a self-administered Microsoft 

Word form e-mailed to respondents. We sent e-mail notifications to 

emergency managers beginning on December 11, 2012.3 We then sent 

the questionnaire and a cover e-mail to officials on December 12, 2012, 

and asked them to fill in the questionnaire form and e-mail it back to us 

within 3 weeks. To encourage emergency managers to complete the 

questionnaire, we sent e-mail reminders and a replacement questionnaire 

to nonrespondents approximately 1 week after, and again 3 weeks after, 

the initial questionnaire was distributed. We also made follow-up phone 

calls to nonrespondents from January 24, 2013, to February 8, 2013. We 

closed the questionnaire on February 20, 2013. We received 27 

completed questionnaires for an overall response rate of 87 percent—

Phoenix and San Antonio did not return the questionnaire. Because we 

attempted to collect data from each of the UASI major cities rather than a 

sample of major cities, there was no sampling error. However, the 

practical difficulties of conducting any questionnaire may introduce errors, 

commonly referred to as nonsampling errors. For example, differences in 

how a particular question is interpreted, the sources of information 

available to respondents, how the responses were processed and 

analyzed, or the types of people who do not respond can influence the 

accuracy of the questionnaire results. We took steps in the development 

of the questionnaire, the data collection, and the data analysis to 

 3

Three cities, Tampa, Philadelphia, and Los Angeles, did not receive e-mail notifications 

because they responded later than other cities to our initial contact attempts. They instead 

received by e-mail the cover letter and questionnaire on the same days in late December 

2012 that they responded to us.
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-13-736 Nuclear Terrorism Response Plans

minimize these nonsampling errors and help ensure the accuracy of the 

answers that were obtained. For example, a GAO social science 

questionnaire specialist designed the questionnaire, in collaboration with 

GAO staff with subject matter expertise. The draft questionnaire was 

pretested to ensure that questions were relevant, clearly stated, and easy 

to comprehend. The questionnaire was also reviewed by external experts 

and a second GAO questionnaire specialist. Data were electronically 

extracted from the Microsoft Word form questionnaires into a commadelimited file that was then imported into a statistical program for 

analyses. No manual data entry was performed, thereby removing an 

additional potential source of error. We examined the questionnaire 

results and performed computer analyses to identify inconsistencies and 

other indications of error and addressed such issues as were necessary. 

Additionally, we contacted respondents to clarify ambiguous responses 

when necessary. Quantitative data analyses and the compilation of openended responses were conducted by the first GAO questionnaire 

specialist using statistical software and working directly with GAO staff 

with subject matter expertise. An independent GAO data analyst checked 

the statistical computer programs for accuracy.

Responses to closed-ended (e.g., Yes/No) questions were summarized

as standard descriptive statistics. Responses to open-ended (i.e., 

narrative) questions were analyzed through content analysis. In 

conducting the content analysis, one GAO analyst reviewed each openended response from each emergency manager to identify recurring 

themes. Using the identified themes, the analyst then developed 

categories for coding the responses. A second GAO analyst reviewed the 

responses from each emergency manager and reviewed the first 

analyst’s themes and categories to reach concurrence on the themes and 

categories. Each of the two GAO analysts then independently reviewed 

the answers to all open-ended questions and placed them into one or 

more of the categories. The analysts then compared their coding to 

identify any disagreements and reached agreement on all items through 

discussion. For the analysis of the open-ended responses on the city’s 

ability to respond to either an RDD or IND, we developed six categories 

based on the number of early response activities a city stated it could 

provide. Specifically, we reviewed the responses looking for whether the 

city would be overwhelmed, the number of specific activities the city 

stated it would conduct, and significant challenges it would face after the 

attack.

To provide important context regarding current federal activities that 

relate to our second and third objectives on RDD and IND response 
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-13-736 Nuclear Terrorism Response Plans

planning and federal response capabilities, we traveled to Chicago to 

meet with federal, regional, state, and city planners who had participated 

in the interagency IND regional planning effort. In addition, we met with 

Department of Homeland Security and FEMA officials to learn how they 

may use insights gained from the interagency IND regional planning effort 

in Chicago for use in other major cities and for developing a potential 

nuclear and radiological annex to the draft federal interagency operational 

plans for the response and recovery mission areas.

To obtain additional information for our third objective on the need and 

availability of federal early response support, we interviewed officials 

involved with federal research initiatives to close gaps in response 

capabilities, as well as those who oversaw planning funds and federal 

technical and resource assistance activities for RDD and IND attacks. 

Specifically, we interviewed FEMA emergency management interagency 

working groups, response planning, and grants officials; National Nuclear 

Security Administration emergency management response operations 

officials; Department of Energy national laboratory officials; and subject 

matter experts. We also reviewed relevant federal guidance documents.

We conducted this performance audit from June 2012 to September 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and

conclusions based on our audit objectives.
Appendix II: Questionnaire

Page 41 GAO-13-736 Nuclear Terrorism Response Plans

Appendix II: Questionnaire
Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix II: Questionnaire

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Appendix III: Fiscal Year 2013 DHS 

Preparedness Grant Programs Funding 

Awarded

Page 58 GAO-13-736 Nuclear Terrorism Response Plans

Preparedness grant programs Grant programs purpose

FY 2013 funding 

awarded

Homeland Security Grant Program 

(HSGP)

Comprised of three related grant 

programs: State Homeland Security 

Program (SHSP), Urban Areas Security 

Initiative (UASI), and Operation 

Stonegarden (OPSG).

For states and urban areas to prevent, protect against, 

mitigate, respond to, and recover from acts of terrorism and 

other threats.

Over $968 million (HSGP)

Over $354 million (SHSP)

Over $558 million (UASI)

$55 million (OPSG)

Over $968 million (HSGP)

• State Homeland Security Program To support the implementation of state homeland security 

strategies to build and strengthen preparedness capabilities 

at all levels. 

Over $354 million

• Urban Areas Security Initiative To enhance regional preparedness and capabilities in 31 

high-threat, high-density areas.

Over $558 million

• Operation Stonegarden To enhance cooperation and coordination among federal, 

state, territorial, tribal and local law enforcement agencies to 

jointly enhance security along the United States land and 

water borders.

$55 million

Emergency Management Performance 

Grants Program

To assist state and local governments in enhancing and 

sustaining all hazards emergency management capabilities.

Over $332 million

Tribal Homeland Security Grant Program To implement preparedness initiatives to help strengthen the 

nation against risk associated with hazards including terrorist 

attacks.

$10 million

Nonprofit Security Grant Program To support physical security enhancements for nonprofit 

organizations determined to be at high risk of a terrorist 

attack and located within one of the FY 2012 UASI-eligible 

urban areas.

$10 million

Intercity Passenger Rail (Amtrak) Program To protect critical surface transportation infrastructure and 

the traveling public from terrorism and increase Amtrak rail 

system resilience.

Over $9 million

Port Security Grant Program To protect critical port infrastructure from terrorism, enhance 

maritime domain awareness, and strengthen risk 

management capabilities to protect against improvised 

explosive devices and other nonconventional weapons.

Over $93 million

Transit Security Grant Program To protect critical surface transportation and the traveling 

public from acts of terrorism and to increase the resilience of 

transit infrastructure.

Over $83 million

Total Awarded Over $1.5 billion

Source: DHS.

Appendix III: Fiscal Year 2013 DHS 

Preparedness Grant Programs Funding 

Awarded
Appendix IV: Comments from the Department 

of Homeland Security

Page 59 GAO-13-736 Nuclear Terrorism Response Plans

Appendix IV: Comments from the 

Department of Homeland Security
Appendix IV: Comments from the Department 

of Homeland Security

Page 60 GAO-13-736 Nuclear Terrorism Response Plans
Appendix IV: Comments from the Department 

of Homeland Security

Page 61 GAO-13-736 Nuclear Terrorism Response Plans
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 62 GAO-13-736 Nuclear Terrorism Response Plans

David C. Trimble (202) 512-3841 or trimbled@gao.gov

In addition to the individual named above, Ned Woodward, Assistant 

Director; Cheryl Arvidson; Thomas Laetz; Eli Lewine; David Lysy; Mike 

Silver; Kathy Smith; and Kiki Theodoropoulos made key contributions to 

this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361400)
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